Dunn Trust v. Commissioner
United States Tax Court
In 1982, AT&T acquired additional stock of Pacific, a subsidiary corporation, in a taxable transaction. Pursuant to a plan of reorganization and divestiture, AT&T transferred all of its Pacific stock, along with other assets, to PacTel Group, a holding company, in a nontaxable exchange for PacTel Group stock, by virtue of which AT&T acquired control of PacTel Group within the meaning of sec. 368(c), I.R.C., 1954. On Jan. 1, 1984, AT&T distributed its PacTel Group stock to…
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In 1982, AT&T acquired additional stock of Pacific, a subsidiary corporation, in a taxable transaction. Pursuant to a plan of reorganization and divestiture, AT&T transferred all of its Pacific stock, along with other assets, to PacTel Group, a holding company, in a nontaxable exchange for PacTel Group stock, by virtue of which AT&T acquired control of PacTel Group within the meaning of sec. 368(c), I.R.C., 1954. On Jan. 1, 1984, AT&T distributed its PacTel Group stock to its shareholders. Held, no portion of the PacTel Group stock distributed to AT&T's shareholders constitutes "other…
1Opinion of the Court
The Edna Louise Dunn Trust, Morgan Guaranty Trust Company, Trustee, Petitioner v. Commissioner of Internal Revenue, Respondent
Dunn Trust v. Commissioner
Docket No. 32031-85
United States Tax Court
86 T.C. 745; 1986 U.S. Tax Ct. LEXIS 120; 86 T.C. No. 46;
April 17, 1986, Filed
Decision will be entered for the petitioner.
In 1982, AT&T acquired additional stock of Pacific, a subsidiary corporation, in a taxable transaction. Pursuant to a plan of reorganization and divestiture, AT&T transferred all of its Pacific stock, along with other assets, to PacTel Group, a holding company, in a nontaxable…
2Cases cited19 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- United States v. American Telephone & Telegraph Co.District Court, District of Columbia · 1983
- Helvering v. HammelSupreme Court of the United States · 1941
- Helvering v. PowersSupreme Court of the United States · 1934
- J. C. Penney Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
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